The Era of Generative AI and Intelligent Automation in Transfer Pricing

We are witnessing an unprecedented shift in the global business landscape, driven by the acceleration of Generative AI and intelligent automation. These technologies are not merely tools, they are reshaping how businesses create, deliver and measure value. In this evolving scenario, Transfer Pricing (TP), the backbone of cross-border inter-company transaction regulation, faces a critical need to evolve.

AI in the Service of TP Compliance

AI is not just a challenge; it’s also a powerful tool for TP compliance, as given below:

  • Natural Language Generation (NLG) can draft tailored local files, intercompany agreements and risk summaries with improved accuracy.
  • AI-driven analytics can simulate transfer pricing outcomes, evaluate scenario-based risk exposure and benchmark intangibles through pattern recognition.
  • Machine Learning models can detect outlier pricing in intercompany transactions, helping preempt scrutiny.

Firms using AI for proactive compliance will likely benefit from reduced audit risks and faster documentation cycles.

Some of the AI Tools Used in Transfer Pricing & Tax Compliance

ONESOURCE TP (Thomson Reuters)
AI features for report generation and risk analysis.

  • Alteryx
    Used in tax teams to prepare data for AI-driven TP models.
  • TP Catalyst
    Benchmarking with Indian and global comparables, Assisting in Local File/TP Study report generation
  • ChatGPT (OpenAI) + Excel/ERP Integration
    Can automate and standardize reporting when integrated with internal systems.

To know more check the link below-

https://uja.in/blog/transfer-pricing/generative-ai-and-intelligent-automation-in-transfer-pricing/

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